International cooperation between governments on fiscal affairs and administrative transparency has a key role in counteracting the phenomena of tax evasion and tax avoidance.
It is common for multinational enterprises around the world to finance their associated subsidiaries in high-level tax jurisdictions through issuing debts rather than equities.
In Part I, Gabriel Magalhães Borges Prata examined Brazil’s thin capitalisation regime. He concludes this discussion here.
The ever growing number of transactions involving MNEs over the past decade has resulted in transfer pricing becoming increasingly important.
The Russian government has joined the ranks of a great number of other jurisdictions which are seeking to introduce mandatory reporting requirements on the unreported capital of its citizens, placed, until now, in offshore locations.
In the first of a two-part series, Flavia Cavalcanti Pepe and H. David Rosenbloom explore the concept of the derivative benefits provision and related tax policy issues.
In this final part, Peter Wilson concludes his discussion of Article 12. Parts 1-3 appeared in the previous three issues of ITR.
The term cloud is used by the information and communication technologies (ICT) industry to indicate, primarily, virtual platforms or infrastructures that allow the execution of codes (services, applications, among others) in various forms across multiple resources, with relevant data.
Kristin Konschnik and Maya Ladno analyse the proposed changes to the US Model Income Tax Treaty, with a particular focus on the limitation of benefits and expatriated entity provisions.
Investment and Indirect Taxes
In Part I, Sylvia H. Torres Caro discussed how Colombia attracts foreign investment and focused her discussion on legal stability agreements put in place by Colombia and other Latin American countries. She concluded by briefly discussing the role played by Colombia’s double tax treaties in securing foreign direct investment. Part II continues this discussion.
In Parts 1 and 2, which appeared in the March and April issues, Maria Cecilia Rossi discussed Cloud Computing and its interaction with the concept of permanent establishment. Here, in Part 3, she concludes her discussion.